Brown I deliberately deferred the remedy question to a second round of argument.

Evidence

The Court did not resolve this ambiguity in Brown I, as the decision came to be called, because it postponed consideration of how to implement its ruling until its next term. — G. Alan Tarr, Judicial Process and Judicial…, 2970

Categorization

• XREF: Explains why implementation doctrine (Brown II) exists as a separate case — the Court’s narrow ruling forced a sequel.